Ontario’s mining sector is a vital part of our economy; a large employer and an economic driver of other industries. Underground mining is an increasingly high-tech operation which, by its nature, presents a range of health and safety hazards. While Ontario’s mining sector is one of the safest in the world, there are always opportunities for improvement.
In December 2013, the Minister of Labour asked the Chief Prevention Officer (CPO) to undertake a Mining Health, Safety and Prevention Review (the Review) focusing specifically on the occupational health and safety needs of the underground mining sector. The goals are to ensure that those who work in Ontario’s mines come home healthy and safe at the end of every shift, and to maintain a productive and innovative mining industry.
Through a highly consultative and transparent process that involved labour, employers, government, health and safety partners, the public and content experts – and included extensive review of the data and experience in other jurisdictions -- the Review identified six key health and safety issues in underground mining:
- Health and safety hazards
- The impact of new technology and management of change
- Emergency preparedness and mine rescue
- Training, skills and labour supply issues
- The capacity of the occupational health and safety system
- The Internal Responsibility System
The first three issues highlight hazards and risks in the underground mining environment, while the last three reinforce the critical importance of people, training, organizations, systems and structures in improving health and safety in Ontario mines. Addressing these issues could significantly improve health and safety outcomes.
1. Health and Safety Hazards
To improve health and safety, the underground mining sector needs a clear understanding of the risks associated with working underground. This understanding is best achieved through a consistent, ongoing risk assessment process. Regular risk assessments help focus attention on the hazards that pose the greatest risk to health and safety. They also ensure that the sector is able to identify new or evolving hazards and take steps to mitigate them.
Through a comprehensive Mining Sector Risk Assessment process conducted collaboratively with labour and employers, the Review ranked the different hazards associated with mining underground and identified five key hazards that pose the greatest risk to health and safety:
- Ground control including the risks associated with seismicity and rockbursts
- Occupational disease focusing particularly on exposure to airborne hazards
- Water management, particularly problematic water in ore and waste passages
- Mobile equipment and the risk of collisions
- Worker fatigue
2. New Technology and Management of Change
Underground mining is a complex high-tech industry and new technologies are continually being introduced into the underground environment. These innovations have produced great advantages: they have reduced a lot of the labour intensive work and helped improve safety, particularly in their ability to improve ground control, prevent falls and control environmental exposure to dust. However, each new technology can mean new risks. To reduce those risks, the mining industry should use a consistent change management process when introducing a new technology and/or a change in process. Based on information provided by risk and change management experts and its review of best practices worldwide, the Review identified the key elements of an effective change management process for underground mining:
- Leadership support
- Worker involvement
- Organizational support(including a system to review the change management process)
- Training for all participants (including change managers)
- A clear risk assessment process evaluating the use of both existing and new technologies, and a policy setting out the circumstances that require change management.
3. Emergency Response and Mine Rescue
Ontario Mine Rescue is a strong system that is well respected for its effectiveness. However, new mining technologies and processes, combined with the trend towards deeper, expanded and more remote mines, are creating challenges for emergency response and mine rescue systems, including:
- Harder to reach, hotter and more humid environments that put great stress on rescue workers and limit the time they can work safely
- Incidents that occur at new exploratory mine sites, which are often remote and don’t have emergency or rescue infrastructure
- Incidents that occur at surface mines and in mining plants, which lack emergency response requirements
To meet these challenges, the mining sector needs highly fit, competent rescue workers who are acclimatized to work in hotter, more humid conditions, skilled in the use of new technologies and have access to support to help them manage the stress of a critical incident. The sector also needs to ensure it has appropriate emergency response plans in place for a wider range of work sites.
4. Training, Skills and Labour Supply Issues
Ontario’s mining sector is facing potential skill and labour shortages due to retirements, demand from new mines, and mine expansions. By 2021, the sector will need to recruit over 6,000 new workers – or more than a third of its current workforce. As a result, the sector will soon be relying on a significant number of relatively inexperienced workers who will be working in increasingly complex environments (i.e. deeper mines, more remote mines) with a growing number of new mining technologies and approaches. Training has always been one of the cornerstones of health and safety in underground mining and it is becoming increasingly critical.
Within the sector, there is strong support for the mandatory training standards for underground mining established by the Ministry of Training, Colleges and Universities and the Common Core training modules overseen by the Mining Tripartite Committee. However, the Review identified a number of improvements, particularly related to training delivery, supervisor training and access to refresher training.
5. Capacity of Ontario’s Occupational Health and Safety System
All partners in Ontario’s mining occupational health and safety system – the Ministry of Labour, the Workplace Safety and Insurance Board, the relevant Health and Safety Associations, the joint occupational health and safety committees or representatives and workers and employers -- play a critical role in creating a health and safety culture. Faced with expected labour shortages, new technologies and processes, and more challenging mining environments, the system must ensure it has the technical expertise to support the sector. This includes establishing processes, procedures and best practices to identify and respond to hazards and risks, such as enforcement and the protection of workers who raise safety issues from reprisals.
6. The Internal Responsibility System
The concept of the Internal Responsibility System (IRS) – where all parties in the workplace contribute to detecting and correcting workplace anomalies that can lead to injury and illness – was introduced in 1976 and is the underpinning of the Occupational Health and Safety Act. However, the IRS has been applied inconsistently within the mining sector. The Review found that the IRS would be more effective if there was:
- Increased enforcement, particularly related to reprisals
- Improved reporting mechanisms, so workers are more involved and aware of reports on health and safety issues, and
- More communication within the mining sector about critical incidents, to help identify emerging risks or trends
The Review’s recommendations involve a range of strategies to respond to the six key issues including: research, legislative changes, training and capacity building, new technologies, and more effective communication.
1. Health and Safety Hazards
To mitigate key health and safety hazards in Ontario’s underground mines, the Review developed a series of recommendations that will: strengthen existing legislation; help to focus the efforts of the Mining Legislative Review Committee on the highest risk health and safety hazards in the mining sector; and encourage the development/adoption of best practices and new technology to improve health and safety.
- 1.1 The Ministry of Labour supported by all relevant health and safety system partners and subject matter experts, to undertake a Mining Sector Risk Assessment with employers and labour every 3 years.
- 1.2 The Ministry of Labour to require employers in the mining sector to conduct risk assessments, which would include measures and procedures to control the risks identified in the assessment as likely to expose a worker to injury and illness. The joint health and safety committee, health and safety representative or workers, be consulted on the risk assessment. Employer risk reassessments are to be done as often as necessary to ensure programs that result from the assessment continues to protect workers.
- 1.3 The Ministry of Labour to work with its Research Advisory Council to focus its grants and research on topics that address the priority hazards identified in the Mining Sector Risk Assessment, and disseminate and act upon the findings where appropriate.
In particular, the Review identified several research opportunities:
- Defining the scientific basis for de-stressing practices and developing guidance materials that define best practices for de-stressing
- Exploring options for collaborating with technology developers to mitigate risks associated with seismicity and rockbursting (i.e. similar to the Australian Centre for Geomechanics model)
- Defining and quantifying the harmful health and safety effects of worker fatigue in the Ontario Mining Sector, and researching other sectors (e.g. transportation, health care and the military) to see how the mining sector compares, and how the problem has been managed.
- 1.4 The Mining Legislative Review Committee to align the majority of its work with the major hazards identified in the sector level risk assessment exercise.
- 1.5 The Ministry of Labour to require that mining employers to address the priority hazards identified in the risk ranking exercise:
- Enhance ground control protection by identifying key elements in the control of these hazards and requiring employers to maintain a record of significant seismic events in addition to incidents of ground instability
- Require employers to prepare a formal plan to manage hazards that cause occupational illness, including requirements for worker and supervisor training and communication
- Require all underground mines employers to have in place a formal water management program
- Specify that precautions be taken by employers to guard against the accumulation of water in bins, ore and waste passes and chutes
- Require all underground mines to have in place a formal traffic management plan.
- 1.6 The Ministry of Labour to review existing occupational exposure limits for a number of key airborne and chemical hazardous substances in underground mines with a view for giving further consideration to the limits for those substances and, if appropriate and advisable, amend Regulation 833. Priority to be given to a review of the occupational exposure limits for silica, nitrogen dioxide and diesel particulate matter (DPM). Other hazards to be considered include sulfur dioxide, and radon.
2. New Technologies and Management of Change Process
To mitigate the risks associated with introducing new technologies into an underground mining environment, the Review made the following recommendation:
- 2.1. The Ministry of Labour to require mine operators to establish and implement a written management of change procedure, to include workers and the joint health and safety committee or health and safety representative.
3. Emergency Preparedness and Mine Rescue
To ensure Ontario’s mine rescue system is able to respond in increasingly challenging mining environments, the Review recommends the following:
- 3.1. The Ministry of Labour to require mining companies to conduct risk assessments to establish Emergency Response Plans for exploration sites, new mines, surface mines and mining plants.
- 3.2 Workplace Safety North to revise the Mine Rescue Handbook to include guidelines for fitness of crew members, critical incident stress management and acclimatization of emergency responders.
- 3.3 The Ministry of Labour to work with stakeholders to develop proposed recommendations regarding the responsibilities of mine rescue crew members and mine owners/employers, with respect to mine rescue operations.
4. Training, Skills and Labour Supply Issues
To ensure that Ontario’s underground mining workforce has the skills to work in more complex, high-tech environments, the Review made the following recommendations:
- 4.1 Enhance supervisor and management training by:
- Requiring the Mining Tripartite Committee, which supports the development of Common Core training, to present to the Ministries of Labour and Training, Colleges and Universities options and recommendations to enhance supervisor and management health and safety training
- Requesting the Mining Tripartite Committee to review the pre-requisites for Supervisor Common Core training and determine the best format for this training (e.g. classroom learning, hands-on experience).
- 4.2 The Ministry of Labour to engage in discussions with the Ministry of Training, Colleges and Universities about the quality and consistency of Common Core training in the underground mining sector, evaluate the current state of that training delivery and identify circumstances where refresher training may be appropriate.
5. Capacity of the Occupational Health and Safety System
To ensure the occupational health and safety system has the skills and capacity to support the underground mining sector, the Review made the following recommendations:
- 5.1 The Ministry of Labour and the relevant Health and Safety Associations to increase their capacity to ensure the health and safety system has the resources to address mining hazards effectively -- particularly the priority hazards identified in the risk-ranking exercise. In particular:
- Increase ministry capacity in geotechnical, mining, mechanical, electrical, structural, and civil engineering
- Increase system partners’ technical capacity/ resources related to industrial hygiene and mechanical issues.
- 5.2 The Ministry of Labour to review its policies and procedures that apply to mining inspectors related to unannounced field visits, reprisals, repeat orders, the training of inspectors and the provision of information to workplace parties and how those policies and procedures are implemented. Take appropriate actions based on the findings of that review. In particular, address the following operational policies and procedures:
- Clarify the use of unannounced proactive field visits
- Clarify the appropriate use of orders versus other methods to achieve compliance for priority hazards especially with regard to repeated non-compliance with the same issue in a specific workplace
- Clarify inspector action to be taken in situations of suspected reprisal
- Align proactive activities, whenever possible, to the priority hazards identified in the sector level risk assessment
- Clarify the training provided to inspectors to address priority hazards and the inspector’s role in the inquest process
- Identify any further training required to support changes in policies and procedures brought about by the Review and/or changes in the regulations
- 5.3 The Ministry of Labour and its partners to review the health and safety system’s ability to meet the needs of the mining sector especially related to providing services to remote communities, training small numbers of trainees, and aligning their training activities to the priority hazards. Take appropriate actions based upon the findings of that review.
- 5.4 The Ministry of Labour to work with the Ministry of Community Safety and Correctional Services to enhance the information supplied to the Chief Coroner’s Office and build better linkages between both ministries. This collaboration includes:
- Conducting and regularly updating an aggregate analysis of all past inquests into mining fatalities
- Holding information sessions with the Chief Coroner to identify opportunities for coroners to use the analysis to improve future inquests into fatalities in the mining sector
6. Internal Responsibility System
The concept of the Internal Responsibility System is the underpinning of the health and safety system. To help it achieve its potential, the Review recommends the following:
- 6.1 The Ontario Mining Association to work with labour representatives to develop an Internal Responsibility System best practice guideline as an industry benchmark and to be endorsed by the Ontario Mining Association for implementation by its members.
- 6.2 The health and safety system to share information both on emerging injury and illness trends, and information on incidents causing serious injury across the industry to trigger preventative actions by workplace parties.
Members of the Review recognize that health and safety is an ongoing process of continuous quality improvement. As the underground mining sector evolves, there is always the potential for new or different risks and hazards. In addition to the formal recommendations listed above, the Review suggests a number of other actions the health and safety system could take to improve health and safety for everyone working in the underground mining sector, including:
- Studying whether the positions, roles and responsibilities stipulated under the Occupational Health and Safety Act meet the current needs of Ontario workplaces
- Studying the health and safety system in surface plants and surface mining
- Continuing to work with subject matter experts to explore priority hazards
- Preserving the database on occupational illness beyond the life of the current project led by the Ontario Cancer Research Centre
- Improving the way research relevant to occupational health and safety in the mining sector is compiled, shared and made available
- Evaluating the impact of alcohol and drugs use in workplace incidents
- Studying the way in which an accreditation program may benefit the mining sector
- footnote Back to paragraph The Internal Responsibility System first appeared in Ontario in the 1976 Report of the Royal Commission on the Health and Safety of Workers in Mines led by Dr. James Ham, “…in Table 51 which detailed occupational health and safety responsibilities for various workplace parties including CEOs, unions, employers, workers and supervisors proportional to the degree of control they exercise in the workplace.